MISSOURI PARKS ASSOCIATION

917 Edgewood Avenue

Columbia, MO 65203

18 August 2002

Commander, Memphis District Corps of Engineers

ATTN: CEMVM-PM-E

167 North Main Street, B-202

Memphis, TN 38103-1894

Dear Sir:

Thank you for the opportunity to comment on the final Revised Supplemental Environmental Impact Statement (RSEIS) for the St. Johns Bayou-New Madrid Floodway Project. The Missouri Parks Association is a statewide nonprofit citizens organization dedicated to the protection, enhancement, and interpretation of Missouri state parks and historic sites. As such, we are particularly concerned about implications of the project for the integrity of Big Oak Tree State Park.

While we are pleased that the RSEIS recognizes the National Natural Landmark status of the park and indicates a commitment to protect the hydrologic functioning of its bottomland forest ecosystem through an engineered solution, we remain deeply concerned about the extreme vagueness and limited nature of that commitment in the present document. For this and other more comprehensive reasons detailed by the U.S. Fish and Wildlife Service (FWS), the Environmental Protection Agency, Environmental Defense, and other organizations, we ask you not to proceed with the project in its present form.

As the report notes, the hydrologic functioning of Big Oak Tree State Park has already been degraded by agricultural drainage in the vicinity of the park, such that the Missouri Department of Natural Resources had planned to construct a ring levee around the park to mimic natural function in an effort to prevent the loss of the oaks for which the park was named. This effort has had to be delayed for years owing to the potentially far more devastating impact of the Corps project. In response to MDNR's objection in its 12 December 2001 comment that the Corps had omitted its earlier proposed compensatory measures, the RSEIS at several points reiterates its "commitment" to an engineered solution.

But the Corps' description of its Big Oak solution is limited to a single sentence indicating "commitment of the Corps to assist in design and implementation of the MDNR plan" and mentioning relief wells, pump wells, control structures, and ditch and levee work (Section 2.6). Just what "assist" means is never explained, as the RSEIS offers no design and no cost figures; nor is there any indication that the Big Oak work has been included in the benefit-cost analysis for the project as a whole.

For more detail we are referred to an attachment (2) to the mitigation appendix (L). In the brief attachment, which reports on a water balance simulation, the only additional details are specification of "20" relief wells and a "3.8K gpm" pump well. And the appendix ends with a sentence that appears to finesse the Corps' commitment with the words "probably" and "mitigation": "Implementation of the MDNR park plan could probably be included and funded, along with the additional improvements, as a mitigation feature of the SJNM project." Use of the word mitigation in this context seems to suggest relegation of the park project to the local partner, which is tantamount to the Corps' washing its hands of ultimate responsibility.

There is a further problem with the Corps' proposal for Big Oak, in that it would rely principally on pumped groundwater to replace natural surface flooding from the Mississippi River. While the RSEIS acknowledges that this will greatly diminish the supply of organic carbon and sediments and increase nitrogen and phosphorus, it dismisses nitrogen and phosphorus as a problem without analyzing available literature on water chemistry in natural wetlands; and it proposes to solve the carbon and sediment reduction by supplementing with ditch water, which may further increase nitrogen and phosphorus. The park is only a few miles from the Mississippi River, so we believe it is both feasible and absolutely imperative to provide for water pumped from the river in order to avoid insofar as possible the potentially deleterious effects of changes in water chemistry.

The mitigation site selection (appendix L, section 10) conveys a further insult to the park. Although the park had been listed as the first of fifteen potential sites for mitigation (section 10.1), it has now been dropped from the priority list in a screening apparently based primarily on suitability for fish spawning habitat (section 10.2). We believe it is absolutely imperative to give highest priority to acquiring and reforesting the 1000+ acres of agricultural lands around the park originally identified for mitigation, as such lands are urgently needed to buffer the effects of agricultural drainage and to permit construction of the ring levee without encroaching on protected acreage currently within the park. The proposed 300-foot riparian corridor connecting Big Oak Tree to Ten Mile Pond, while desirable, can not substitute for buffer lands surrounding the park. We are pleased to note that the U.S. Fish and Wildlife Service, in its coordination report (appendix E), also recommends that such buffer lands be acquired, restored, and incorporated in the park.

We are particularly disturbed to note the Corps' outright dismissal of numerous comments in appendix M by the U.S. FWS, EPA, Environmental Defense and other organizations, especially regarding disagreements over the specific determination of wetland acres affected by the project, the impact of the project on bottomland hardwood forests, and the need for more detail on compensatory measures. Although the Corps' responses to comments by MDNR, NPS and others with specific reference to Big Oak Tree State Park would seem to be more forthcoming, in fact the lack of detail about the proposed structural solution and its costs, the vaguely stated commitment, the dismissal of certain key water chemistry concerns, and the elimination of agricultural lands surrounding the park from the list of mitigation sites cast the Corps' degree of commitment to the park into grave doubt.

In view of the enormously destructive impact of the project on wetland ecosystems in the Missouri Bootheel—most especially those of national landmark status in Big Oak Tree State Park—and in view of the apparent omission of costs for Big Oak Tree in the already razor-thin benefit:cost ratio for the project, it appears to us that the St. John's Bayou-New Madrid Floodway Project is not economically justifiable and that it is most certainly not in the national interest.

For these reasons we ask you not to sign the record of decision but rather to call for further review of a more limited, less environmentally destructive, and more economically feasible solution to the most pressing problems in the area. Thank you for your consideration of these comments.

Sincerely,

Susan Flader

President

cc: Stephen Mahfood, Director MDNR

Bob Holden, Governor